Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
AO levied penalty u/s 271(1)(c) as assessee failed to file return u/s 139 or in response to notice u/s 148, despite receiving substantial contract receipts of Rs. 2.5 crore. ITAT upheld penalty, rejecting assessee's plea that addition was estimated, as assessee defied statutory requirements and didn't furnish details during assessment proceedings. Assessee's contention of auditor's failure being the cause was rejected, as filing return u/s 139 is assessee's responsibility. Penalty confirmed.
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